ACHA Submits Comments to Internal Revenue Service on Eligibility for Minimum Essential Coverage for Purposes of the Premium Tax Credit

8/23/13.

On July 15, 2013, the Internal Revenue Service (IRS) posted Notice 2013-41: Eligibility for Minimum Essential Coverage for Purposes of the Premium Tax Credit [pdf] that, among other provisions, contained guidance affecting students who have access to coverage under an institution’s self-funded plan. Based on this guidance that determines their eligibility for minimum essential coverage “only if the individual is enrolled in the coverage”, students who have access to coverage under a self-funded plan (but are not enrolled), would also have the option to purchase coverage through an Affordable Insurance Exchange and be eligible for premium tax credits if they choose to do so.

On behalf of the ACHA membership, ACHA President Pat Ketcham has submitted comments [pdf] supporting “eligibility based on enrollment” so that these students may have the option of purchasing coverage through the exchanges. ACHA’s comments also advocated for inclusion of student health plans (fully insured or self-funded) on the exchanges, and for fixing a gap in eligibility for Medicaid coverage for the lowest income students that resulted from an earlier Supreme Court decision regarding Medicaid expansion. The gap appears to be an unintended consequence from that decision. The letter also pledges ACHA’s continued commitment and vigilance in promoting high-quality coverage for the nation’s college students.